Modified: March 28, 2021

Inteligems Privacy Policy

Inteligems, Inc. (“Inteligems”, “we”, “our”, or “us”) offers tools that improve conversations for sales, product marketing, and recruiting online (the “Service”), and websites or online extensions, including but not limited to www.Inteligems.io (the “Websites”). This Privacy Policy (the “Policy”) explains how we collect, process, use, and disclose Personal Data (or “personal information”) collected/generated through the Service, Websites, or other ways, and what choices you have for such information. It is important that you also read the other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Policy supplements the other notices and is not intended to override them.

By using the Service, you hereby warrant and represent that you are over 18 years of age. PLEASE DO NOT USE, INSTALL, OR ACCESS THE SERVICES IF YOU DO NOT AGREE TO THIS PRIVACY POLICY. 

By accessing or using the Service and Websites, you acknowledge and agree that you have read, understand, and agree to be bound by this Policy. If you do not agree with this Policy, do not access, or use the Service, Websites, or any other part of Inteligems’ business.

1. Which Privacy Terms are Applicable to Me?
2. Privacy Terms for End Users
3. Privacy Terms for Website Visitors
4. Privacy Terms for Other Individuals
5. Additional Privacy Terms for All Individuals
6. Privacy Information for Individuals in the EU/UK
7. Privacy Information for California Residents
8. Talk to Us

1. Which Privacy Terms Are Applicable to Me? 

Inteligems collects information about different types of individuals. Please see the following definitions to determine which type of individual you are. One or all of the privacy terms may be applicable.

End Users. These are individuals who use the Service as part of a paid Inteligems subscription plan. 
Website Visitors. These are individuals who use the Websites. 
Other Individuals. These are individuals about whom we collect Personal Data but are not necessarily End Users or Website Visitors. 

2. Privacy Terms for End Users 

If you are an End User, the specific terms agreed to between Inteligems and the organization (e.g., your employer or another entity or person, called the “Customer”) that entered into a separate agreement (“Customer Agreement”), governs the collection and processing of information collected from you through the Customer’s instance of the Service (“Account”). Because the Customer controls the Account used by End Users, if you have any questions about the Customer’s specific Account settings and privacy practices, please contact the Customer whose Account you use.

2.1. Collection/Generation of End User Information

This section explains the information we collect/generate from End Users. We do not require End Users to provide us with information. However, certain information is required to provide you with access to the Service (such as Account Information or authentication information), and other information may be collected automatically as you use the Service.

Account Content. All email and chat messages, and calendar data and other content submitted through the Service is collected, used, and shared by Inteligems in accordance with the Customer’s instructions, including any applicable terms in the Customer Agreement, or as required by applicable law. The Customer, and not Inteligems, determines its own internal policies regarding storage, access, modification, deletion, sharing, and retention of Account Content which may apply to your use of the Service. For example, a Customer may provide or remove access to the Service or enable or disable third party integrations. Please check with the Customer about their policies and settings with respect to the Account Content that is collected when using the Service.

Account Information. To set up your Inteligems account, the Customer will provide us with basic information about you which may include your name, email address, zip code, department, gender, and other information.

Service Usage Information. As you access the Service, we collect information about how you use and interact with the Service. Such information includes:

Device information – the type of device you are using, its operating system, device ID, and other unique device identifiers.

Log files – web request, browser type, and settings, referring/exit pages and URLs, number of clicks, date and time stamp information, language preferences, data from cookies and similar technologies, and other such information.

Metadata – high-level information about the way you work in your Account. For example, we may log the features and embedded Service content you interact with; and what, if any, third party services and integrations you use.

Location information – general information about the location of the device from which you are accessing the Service.

Recorded information.  When you use Inteligems application for Zoom, Teams, Google Hangout, GotoMeeting, other third-party web conferencing tools, or cloud-based business communications,  (“Cloud-based Communications App”), Inteligems will either automatically record or receive an upload of audio and video from your Cloud-based Communications session (including any items shared on screen, and all Personal Data included). The legal bases for our collection of this information are the performance of the Customer Agreement with you or the entity you represent (the Customer). We use this information to provide our Service. If we were not able to collect this information, we would not be able to provide our Service. We retain the Recorded Information and related personal information for the period the applicable Customer has chosen in the account settings section of the Inteligems platform or up to 36 months. Thereafter, we archive and use them only for necessary purposes, such as internal audits and legal disputes and proceedings.

Additional Information. You may provide us with information when you interact with us in other ways, such as when you submit requests or questions to us via forms or embedded chat windows; information you provide in connection with Inteligems research studies in which you choose to participate; and requests for customer support and technical assistance.

Information Collected from Third-Party Integrations. If you choose to use or connect to third-party integrations (e.g., SalesForce, HubSpot, Zoom, Teams, Slack, Google Meet, Microsoft Calendar, etc.) through the Service, or if you are required or permitted to do so by a Customer, such third parties may allow us to have access to and store Additional Information and Recorded Information about your interaction with those services as it relates to your use of our Service. 

Metrics. These are the personalized metrics generated using Account Content, Recorded Information, Information Collected from Third-Party Integrations, and Service Usage Information.

Aggregated Non-Identifiable Data.  We collect, use, and share aggregated non-identifiable information such as statistical or demographic data for legitimate business purposes. Aggregated data may be derived from End User Data but is not considered Personal Data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used under this Policy.

2.2. How Does Inteligems Use End User Information?

Inteligems may use information collected/generated from and about End Users only as necessary:

• To provide, maintain, and improve the Service.
• For internal training and quality control purposes.
• To protect the Service and our users and prevent or address technical or security issues.
• To resolve support requests.
• To investigate good faith alleged violations of the Customer Agreement or our Terms of Service.
• Under applicable legal obligations, or to comply with a valid legal subpoena, request, or other lawful process.
• As otherwise outlined in our Customer Agreement or as expressly permitted by the Customer.

Additionally, Account Information, Service Usage Information, Information from Third Party Integrations, Recorded Information, and Additional Information may be also used only as necessary:

• To help us better understand user interests, needs, and to customize the Service for our users.
• To engage in analysis, research, and reports regarding use of the Service.
• To respond to your requests for information.
• To communicate with you about important notices and updates regarding the Service, such as to inform you about changes in the Service, our service offerings, or security and fraud issues. You may not opt-out of these important Service-related notices and updates.
• To communicate with you about promotions, offers, and news about Inteligems. You may unsubscribe from promotional communications.

2.3. Sharing of End User Information

We may share the information we collect/generate from End Users as follows:Customer Agreement. We may share the information per the Customer Agreement.

Service Providers. We may provide access to or share your information with third parties that use the information only to perform services on our behalf, such as sales, marketing, communications, customer support, technical development/admin, provision of content and features, project management, integration, research, analytics, data storage, data processing, security, fraud prevention, and other services.

Business Transactions. If Inteligems is involved in a merger, acquisition, dissolution, sale of all or a portion of its assets, or other fundamental corporate transaction, or if the ownership of all or substantially all of our business changes, we may transfer your information to the new owner so that the Service can continue to operate. In such case, your information would remain subject to the promises and commitments contained in this Policy until such time as this Policy is updated or amended by the acquiring party upon notice to you. If such transfer is subject to additional mandatory restrictions under applicable laws, Inteligems will comply with such restrictions.

Applicable Law. We may share the information when we believe in good faith that release is necessary to comply with applicable laws, rules, or regulations (including any applicable laws, rules, or regulations outside your country or state of residence).

Please note that while Inteligems does not proactively display your Metrics to your employer (or another entity or person, called the “Customer”), theoretically, it may be viewable by others within your organization, for example, if your employer takes control of your login credentials.

2.4. Data Subject Rights

Contact your Account owner(s) or administrator(s) to exercise any data subject rights you have under applicable local laws, including your ability to access, delete, rectify, transfer, or object under the GDPR. Alternatively, clicking the “Delete Account” button located in your account’s settings will delete your “Account Content” and “Metrics.”

2.5. Is Inteligems a controller or processor of End User Information?

According to the General Data Protection Regulation (“GDPR”), if you are an End User located in the European Union/UK, the Customer is the data controller for the processing of your Account Content, Account Information, Additional Information, Recorded Information, Information Collected from Third-Party Integrations, and Metrics and Inteligems is the data processor, meaning that we collect and process such information solely on behalf of the Customer. In general, Inteligems is the data controller of Service Usage Information and other information.

2.6. Legal Bases

According to the GDPR, if you are an End User located in the European Union/UK, we rely on the following legal bases for using the Service Usage Information and other information we collect through your use of the Service:

Legitimate Interests. Where use of your information is necessary for our legitimate interests or the legitimate interests of others, as described in the “How Does Inteligems Use End User Information” section.

Recording Consent Where you obtain consent necessary to record a call or web conference meeting. If you do not provide approval or consent for a voice recording, we will not record it. We record calls to automate note taking, extract insights for CRM updates, and for your internal training purposes. We recommend you do not record or share confidential or sensitive personal information of any kind without the express consent of the parties being recorded. We do not request and have no intention to collect this type of information. We also do not intend to record people around you. Please make sure that other persons in your surroundings are not recorded unintentionally, or that you have provided them with this notice and they acknowledged their approval of the recording. We do not intend to collect personally identifiable information from anyone we know to be under 18 years old.  Please take appropriate action to delete recordings that are not obtained without consent or from persons under age 18. 

Legal Obligation. Where use of your information is necessary to comply with a legal obligation.

Contract. Where use of your information is necessary to perform our obligations under a contract with you (for example, to comply with the Terms of Service which you accept by browsing the Websites)

3. Privacy Terms for Website Visitors

If you visit the Websites, regardless of whether you are also a user of the Service, the following rules apply to you.

3.1. Collection of Website Visitor Information

When you use the Websites, we collect the following information about you:

Website Usage Information. As you browse the Websites, we collect information about how you use and interact with the Websites. Such information includes:

Device information – the type of device you are using, its operating system, device ID, and other unique device identifiers.Log files – web request, IP address, browser type and settings, referring/exit pages and URLs, number of clicks, date and time stamp information, language preferences, data from cookies and similar technologies, and other such information.

Metadata – high-level information about the way you use the Websites. For example, we may log the features links you interact with. 

Location Information – We collect and process general information about the location of the device from which you are accessing the Websites (e.g., country level or geographic location inferred from an IP address).

Disabling Location Tracking. You can grant or revoke your consent to our collection of your location at any time or prevent us from continuing to access your GPS information by disabling the GPS or other location-tracking functions on your device, provided your device allows you to do this. 

Contact Information. If you submit a request for information or a question through the Websites, you may be asked to provide us with basic information including your name, email address, address, phone number, and job information. We will also keep records of the communication, the question/request you raised, and how it was resolved. If you choose to participate in a Inteligems research study offered through the Websites, we will also collect basic contact information from you in connection with such activity.

3.2. Cookies and Similar Technologies

To collect the Website Usage Information discussed above, we and our service providers use cookies, server logs, tags, SDKs, tracking pixels, and other similar tracking technologies. A cookie is a small text file that is placed on your computer or mobile device when you visit a site, that enables us to: (i) recognize your computer and login session; (ii) store your preferences and settings; (iii) understand which pages of the Websites you have visited; (iv), enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform analytics; and (vi) assist with security and administrative functions. A web server log is a file where website activity is stored. An SDK is a section of code that we embed in our applications and software to allow third parties to collect information about how users interact with the Websites. 

Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads and/or email, and that are designed to provide usage information like ad impressions or clicks, email open rates, measure the popularity of the Websites and associated advertising, and to access user cookies. 

We use several third-party services which use tracking pixels on our website to collect web behavior information that we use to provide Services, improve our products, user experience,  and other purposes. These include:

(a)   Zoho is a CRM and marketing automation tool provided by Zoho, Inc., which we use to improve our customer outreach. You can learn more about how this tool collects information by visiting Zoho’s privacy policy https://www.zoho.com/privacy.html.

(b)   Google Ads – We use conversion pixels from Google to track the success of campaigns and to learn about which cross sections of people are most interested in our products and services. You can learn more about how Google collects data at https://policies.google.com/technologies/ads?hl=en-US and specifically about Google enables customers like us to use conversion tracking here: https://support.google.com/google-ads/answer/1722022.

• You can learn more about how to opt-out by browsing Google’s opting-out and privacy pages located at www.google.com, or the Network Advertising Initiative website located at www.networkadvertising.org. In addition, you may set browser and system preferences for how other third parties serve ads to you.

(c)   Google Analytics. We use Google Analytics to evaluate how users use our website and who uses our website. You can learn more about how Google collects and uses data by visiting https://policies.google.com/technologies/partner-sites  (“How Google uses information from sites or apps that use our services”).

(d)   Google Tag Manager. We use Google Tag Manager to track website traffic. You can learn more about Google Tag Manager and how it is used at https://support.google.com/tagmanager/answer/6102821?hl=en. Google’s use of data collected through Tag Manager is governed by its privacy policy, available at https://policies.google.com/privacy.

(e)   We use Facebook for social media advertising and to generate new leads and traffic to our website. You can learn more about how Facebook collects information generally and on behalf of its customers like us, at https://www.facebook.com/policy.php.

(f)    We use LinkedIn for social media advertising and to generate new leads and traffic to our website social media advertising. You can learn more about how Linkedin collects information generally and on behalf of its customers like us, at https://www.linkedin.com/legal/privacy-policy.

As we adopt additional technologies, we may also gather information through other methods. Please note that you can change your settings to notify you when a cookie is being set or updated, or to limit and even block cookies. 

Disabling Cookies. To learn more about cookies, please visit http://www.allaboutcookies.org/. Most Internet browsers allow you to delete or decline cookies by changing your browser settings. The “Help” function in the toolbar of most browsers (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari) should indicate how you can set your browser to notify you before accepting cookies or to disable cookies entirely. However, if you refuse to accept cookies, you may limit your use of certain features or functions on our Website and Service. 

You can read our Cookie declaration here [Inteligems cookie declaration]

You can at any time change or withdraw your consent from the Cookie Declaration on our Site.  

3.3. How Does Inteligems Use Website Visitors Information

3.3.1. We use the information collected from Website Visitors for a variety of purposes including:

• To provide, maintain, and improve the Websites.
• For internal training and quality control purposes.
• To protect the Website and our users and prevent or address technical or security issues.
• To investigate in good faith alleged violations of our Terms of Service.
• Under applicable legal obligations, or to comply with a valid legal subpoena, request, or other lawful process.
• To help us better understand Website Visitor interests and needs and customize the advertising and content you see on the Websites.
• To engage in analysis and research regarding the use of the Websites.
• As otherwise outlined in our Terms of Service or as expressly permitted by you.

3.3.2. Additionally, Contact Information may also be used only as necessary:

• To respond to your requests for information.
• To communicate with you about important notices and updates regarding the Website, such as to inform you about changes on the Website, or security and fraud issues. You may not opt out of these important Website-related notices and updates.
• To communicate with you about promotions, offers, and news about Inteligems. You can unsubscribe from such promotional communications.
• For administrative purposes, such as billing, account administration, account integration, or other similar/related purposes.

Imported Contacts or Google User Data. If you provide us with access to your contacts, you acknowledge and agree that we may use such information as part of the service, as described in this Policy, and you confirm that you have the rights and permissions to provide such access to your contacts. Similarly, when you provide us with permissions and access to your Google account, we may access and use your contacts for the purpose of the service. At any time, you may decide to opt-out of enabling us to access your contacts by sending such requests to privacy@Inteligems.io.

3.4. Website Analytics and Advertising

Website Analytics. We may use third-party web analytics services on our Websites to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.

Online Advertising. The Websites may integrate third-party advertising technologies that allow for the delivery of relevant content and advertising on other websites you visit. The ads may be based on various factors such as the content of the page you are visiting, the information you enter such as your age and gender, your searches, demographic data, and other information. These ads may be based on your current activity or your activity over time and across other websites and online services and may be tailored to your interests.

Third parties, whose products or services are accessible via the Websites, may also place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about you as discussed above.

We neither have access to nor does this Policy govern, the use of cookies or other tracking technologies that may be placed on your device you use to access the Websites, by non-affiliated third parties. For more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out Link, the Digital Advertising Alliance’s Consumer Opt-Out link, or Your Online Choices (if you are located in the EU, Switzerland, or the UK) to opt-out of receiving tailored advertising from companies that participate in those programs. 

To opt out of Google Analytics for display advertising or customize Google display network ads, visit the Google Ads Settings page. We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.

Please note that if you exercise the opt-out choices above, you will still see advertising on websites, but it will not be tailored to you based on your online behavior over time.

Notice Concerning Do Not Track. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our Websites for third party purposes, and that is why we provide the variety of opt-out mechanisms listed above. However, we do not currently recognize or respond to browser initiated DNT signals. To learn more about Do Not Track, you can do so here.

3.5. Sharing of Website Visitor Information

We share the information we collect through the Websites with the following:

Terms of Service. We may share the information under the Terms of Service.

Service Providers. We may provide access to or share your information with third parties that use the information only to perform services on our behalf such as sales, marketing, communications, customer support, technical development/admin, provision of content and features, project management, integration, advertising, analytics, research, data storage, data processing, security, fraud prevention, and other services.

Business Transactions. If Inteligems is involved in a merger, acquisition, dissolution, sale of all or a portion of its assets, or other fundamental corporate transaction, or if the ownership of all or substantially all of our business changes, we may transfer your information to the new owner so that the Websites can continue to operate. In such case, your information would remain subject to the promises and commitments contained in this Policy until such time as this Policy is updated or amended by the acquiring party upon notice to you. If such transfer is subject to additional mandatory restrictions under applicable laws, Inteligems will comply with such restrictions.

Applicable Law. We may share the information when we believe in good faith that release is necessary to comply with applicable laws, rules, or regulations (including any applicable laws, rules, or regulations outside your country or state of residence).

Consent. We may also disclose your information to third parties with your consent to do so.

3.6. Third Party Links And Services

The Websites may contain links to third-party websites and functionalities. If you choose to use these third-party services, you may disclose your information not just to those third parties, but also to their users and the public more generally depending on how their services function. Because these third-party websites and services are not operated by Inteligems, Inteligems is not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your information will be subject to the privacy policies of the third-party websites or services, and not this Policy.

If you initiate these connections, you also understand that we will share information about you that is required to enable your use of the third-party integration through the Service. If you do not wish to have this information shared, do not initiate these connections. By enabling these connections, you authorize us to connect and access the information provided through these connections, and you understand that the privacy policies of these third parties govern such connections.

3.6.1           Google DisclosureInteligems’ use and transfer to any other app of information received from Google Accounts will adhere to Google API Services User Data Policy, including the Limited Use requirements.

3.7. Is Inteligems a controller or processor of Website Visitor Information

According to the GDPR, if you are a Website Visitor located in the European Union/UK, Inteligems is the data controller of Website Visitor information.

3.8. Legal Bases

According to the GDPR, if you are a Website Visitor located in the European Union/UK, we rely on the following legal bases for using the Website Visitor Information and other information we collect through your use of the Website:

Legitimate Interests. Where use of your information is necessary for our legitimate interests or the legitimate interests of others as described in the “How Does Inteligems Use Website Visitors Information” section.

Legal Obligation. Where use of your information is necessary to comply with a legal obligationWhere we have your consent to process data in a certain way. When we process your personal data based on your consent (i.e., for direct marketing purposes or otherwise), you have the right to withdraw your consent at any time by contacting us. However, this will not affect the lawfulness of the processing based on such consent before your consent was withdrawn. In commercial email messages, you can also opt out by clicking the “unsubscribe” link located at the bottom of such emails and following the instructions.

Contract. Where use of your information is necessary to perform our obligations under a contract with you (for example, to comply with the Terms of Service which you accept by browsing the Websites)

4. Privacy Terms for Other Individuals

Regardless of whether or not you are a Website Visitor or End User, the following terms apply to you if we have collected your personal data, for example from referrals or lead generation, or if someone has provided us with access to their contacts.

4.1. Collection of Information about Other Individuals

We may collect the following information about you:

Contact Information. This is basic information including your name, email address, phone number, postal address, and job details.

Recorded Information. We may record some marketing and sales calls and will obtain appropriate consent from you where required.

4.2. How Does Inteligems Use Information about Other Individuals?

Contact Information may be used only as necessary:

• To provide, maintain, and improve the applicable Inteligems service.
• For internal training and quality control purposes.
• To protect the applicable Inteligems service and other individuals and prevent or address technical or security issues.
• To investigate in good faith alleged violations of our Terms of Service.
• Under applicable legal obligations, or to comply with a valid legal subpoena, request, or other lawful process.
• As otherwise outlined in our Terms of Service or as expressly permitted by you.
• To communicate with you about important notices and updates regarding the applicable Inteligems service, such as to inform you about changes in the applicable Inteligems service, or security and fraud issues. You may not opt out of these important service-related notices and updates.
• To communicate with you about promotions, offers, and news about Inteligems. You can unsubscribe from such promotional communications.
• For administrative purposes, such as billing, account administration, account integration, or other similar/related purposes.

4.3. Sharing of Information about Other Individuals

We share the information we collect about Other Individuals with the following:

Terms of Service. We may share the information under the Terms of Service.

Service Providers. We may provide access to or share your information with third parties that use the information only to perform services on our behalf such as sales, marketing, communications, customer support, project management, integration, advertising, research, data storage, data processing, security, fraud prevention, and other services.

Business Transactions. If Inteligems is involved in a merger, acquisition, dissolution, sale of all or a portion of its assets, or other fundamental corporate transaction, or if the ownership of all or substantially all of our business changes, we may transfer your information to the new owner so that the Websites can continue to operate. In such case, your information would remain subject to the promises and commitments contained in this Policy until such time as this Policy is updated or amended by the acquiring party upon notice to you. If such transfer is subject to additional mandatory restrictions under applicable laws, Inteligems will comply with such restrictions.

Applicable Law. We may share the information when we believe in good faith that release is necessary to comply with applicable laws, rules, or regulations (including any applicable laws, rules, or regulations outside your country or state of residence).

Consent. We may also disclose your information to third parties with your consent to do so.

4.4. Is Inteligems a controller or processor of Information about Other Individuals

According to the GDPR, if you are located in the European Union/UK, Inteligems is the data controller of information about Other Individuals.

4.5. Legal Bases

According to the GDPR, if you are located in the European Union/UK, we rely on the following legal bases for using the information we collect about Other Individuals:

Legitimate Interests. Where use of your information is necessary for our legitimate interests or the legitimate interests of others as described in the “How Does Inteligems Use Information about Other Individuals” section.

Legal Obligation. Where use of your information is necessary to comply with a legal obligation

Consent. Where we have your consent to process data in a certain way. When we process your personal data based on your consent (i.e., for direct marketing purposes or otherwise), you have the right to withdraw your consent at any time by contacting us as provided below. However, this will not affect the lawfulness of the processing based on such consent before your consent was withdrawn.

5. Additional Privacy Terms for All Individuals

The following information about Inteligems privacy practices applies to all individuals whose personal data is processed by Inteligems.

5.1 Changes To Our Privacy Policy

We reserve the right to amend this Policy at any time to reflect our data collection and use practices. We will make the revised Policy accessible through the Service and Websites, or by sending you an email to the email address on file. If we make a material change to the Policy, we will comply with applicable legal requirements to provide you with notice and/or consent.

5.2. Is My Personal Data Secure?

We have implemented technical and organizational measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure, or access. However, no method of transmission over the Internet, and no means of electronic or physical storage, is absolutely secure, and thus we cannot guarantee the absolute security of that information. 

We consider data security a top priority and we do our best to keep your Personal Data secure. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. Such measures include:

Infrastructure Security

End-to-End Network Isolation
• External & Internal enforcement points
• Server HardeningDenial of Service (DOS) Protection
• Segregation between Office and Production Networks
• Penetration Tests

Application Security

Access Control
• Data Encryption
• Vulnerabilities Management
• Segregation of Customer Data

Operational Security
Identity and Access Management (IAM)
• Password Policy
• Recertification of Access Permissions:
• Configuration and Patch Management
• Security Incident Response

Also, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. Our policy is to require such persons to only process their Personal Data on our instructions and to execute confidentiality agreements (or be otherwise subject to a duty of confidentiality).

We have put in place procedures to deal with a personal data breach (whether such breach is actual or a probable threat) and will notify you and any applicable regulator of a breach where we are legally required to do so.

Please keep in mind that we update and change the security measures we employ from time to time. Also, no method of transmission over the Internet, or method of electronic storage, is 100% secure. As a result, although we strive to protect your Personal Data, we cannot promise or guarantee that such information will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us under the “Talk to Us” section below.      

5.3. Marketing Practices and Choices

If you receive email from us, we may use certain analytics tools, such as clear GIFs, to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns. You may instruct us not to use your contact information to contact you by email, or phone regarding products, services, promotions, and special events that might appeal to your interests by getting in touch with us using the contact information listed “Talk to us” section at the end of this Policy. In commercial email messages, you can also opt out by clicking the “unsubscribe” link located at the bottom of such emails and following the instructions. Please note that, regardless of your request, we may still use and share certain information as permitted by this Policy or as required by applicable law. For example, you may not opt out of certain operational or service-related emails, such as those reflecting our relationship or transactions with you.

5.4. Data Retention

We will retain your information for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law, required to resolve disputes, or enforce our agreements, or where the Customer Agreement requires or permits specific retention or deletion periods.

In some circumstances, we may anonymize your Personal Data (so that it can no longer be associated with you) for research, aggregated data, or statistical purposes in which case we may use this information indefinitely without further notice to you.

5.5. Combined Information

We may combine the information that we collect through the Service or Websites with information that we receive from other sources, both online and offline, and use such combined information under this Policy. If, however, the collection of any information about you is governed by a Customer Agreement, information will only be combined and used under such Customer Agreement and the sections of this Policy apply to End Users.

5.6. Aggregate/De-Identified Data

We may aggregate and/or de-identify information collected through the Service or Websites so that such information can no longer be linked to you or your device. We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and analytics, and marketing purposes, and may also share such data with any third parties, including advertisers, partners, affiliates, services providers, sponsors, event promoters and others.

5.7 Transfers of Personal Data

Our private company is headquartered in the United States of America. We process information, on your behalf, on secure services located in the US. If you are a resident in a jurisdiction where the transfer of your personal information outside of your territory requires your consent, then you will provide us your necessary consent to such transfer.

To facilitate our operations, we may transfer, store, and process your personal data in jurisdictions other than where you live including in the United States. Laws in these countries may differ from the laws applicable to your country of residence. For instance, if you are a European Economic Area (EEA) data subject and your personal data is shared with our affiliates, partners, or third-party service providers acting on our behalf outside of the EEA, then it is done so under necessary means to ensure an adequate level of protection. 

We may need to transfer your information, including your Personal Data, to other countries, other countries around the world where our service providers, such as our transcribers, may be located.

When we transfer Personal Data of EU individuals out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• Where we use service providers, these service providers are bound by specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
• The country in which the service provider is located has been approved by the European Commission as providing legal adequate protection of Personal Data.

Please contact us at Privacy@Inteligems.io if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

5.8 Data Security

We consider data security a top priority and we do our best to keep your Personal Data secure. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. Such measures include:

Infrastructure Security

End-to-End Network Isolation
• External & Internal enforcement points
• Server Hardening
• Denial of Service (DOS) Protection
• Segregation between Office and Production Networks
• Penetration Tests

Application Security

Access Control
• Data Encryption
• Vulnerabilities Management
• Segregation of Customer Data

Operational Security

• Identity and Access Management (IAM)
• Password Policy
• Recertification of Access Permissions:
• Configuration and Patch Management
• Security Incident Response

Also, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. Our policy is to require such persons to only process their Personal Data on our instructions and to execute confidentiality agreements (or be otherwise subject to a duty of confidentiality).

We have put in place procedures to deal with a personal data breach (whether such breach is actual or a probable threat) and will notify you and any applicable regulator of a breach where we are legally required to do so.

Please keep in mind that we update and change the security measures we employ from time to time. Also, no method of transmission over the Internet, or method of electronic storage, is 100% secure. As a result, although we strive to protect your Personal Data, we cannot promise or guarantee that such information will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us under the “Talk to Us” section below.      

6. Privacy Information for Individuals in the EU/UK

6.1. Data Subject Rights

Inteligems respects your rights and control over your personal data. You may exercise any of the following rights:

Right of Access: You have the right to be informed of and request access to the personal data we process about you. Upon request, we will confirm whether we hold or are processing personal data that we have collected about you.

Right to Correction: You have the right to request that we amend or update your inaccurate or incomplete personal data.

Right to Erasure: You have the right to request deletion of your personal data.

Right to Restrict: You have the right to request that we temporarily or permanently stop processing all or some of your personal data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Right to Object: You have the right, at any time, to object to us processing your personal data on grounds relating to your particular situation; the right to object to your personal data being processed for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Right to Data Portability: You have the right to request a copy of your personal data in electronic format and the right to request that we transmit that personal data for use in another party’s service. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent:  At any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Under certain circumstances we will not be able to fulfill your request, such as if it interferes with our regulatory obligations, affects legal matters, we cannot verify your identity, or it involves disproportionate cost or effort, but in any event, we will respond to your request within a reasonable timeframe and provide you an explanation. To make such a request for us, please email us at privacy@Inteligems.io.

Please note that for personal data about you that we have obtained or received for processing on behalf of a separate, unaffiliated entity–which determined the means and purposes of processing, all such requests should be made to that entity directly. We will respond and support any instructions they provide us for your personal data.

6.2. Additional

For EEA/UK data subjects, our data protection officer may be reached at our principal place of business or by emailing privacy@Inteligems.io. 

EEA/UK data subjects have the right to lodge a complaint with a supervisory authority concerning Inteligems data processing activities.

7. Privacy Information for California Residents

If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).

7.1. Categories of personal information we collect

Under the CCPA, we are required to provide you with the “categories” of personal information we collect. The categories we collect are: